Code for prevention of Insider Trading in the Securities of Petronet LNG Limited (PLL)
1. BACKGROUND
In line with SEBI (Prohibition of Insider Trading) Regulations, 1992, as amended, the Board of
Petronet LNG Limited (PLL) at its meeting held on 28.05.2004 had approved the “Code of Internal
Procedures and Conduct for Prevention of Insider Trading in dealing with the securities of PLL” which
became effective from 01.06.2004.
SEBI vide notification dated 15.01.2015 repealed the SEBI (Prohibition of Insider Trading)
Regulations, 1992 and replaced the same with SEBI (Prohibition of Insider Trading) Regulations, 2015
to put in place a framework for prohibition of Insider Trading in securities and to strengthen the legal
framework thereof. Accordingly, the Board of PLL at its meeting held on 30.07.2015 had approved
and adopted ‘Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive
Information’ and ‘Code of Conduct to Regulate, Monitor and Report trading by Insiders of the
securities of PLL’ , which became effective from 15.05.2015.
Thereafter, SEBI vide notification dated 31.12.2018 notified SEBI (Prohibition of Insider Trading)
(Amendment) Regulations, 2018 which amended the SEBI (Prohibition of Insider Trading)
Regulations 2015 and would become effective from 01.04.2019.
Accordingly, the new code ‘Code for Prevention of Insider Trading in the Securities of Petronet
LNG Limited (PLL)’ in line with SEBI (Prohibition of Insider Trading) (Amendment) Regulations,
2018 shall become effective from 01.04.2019 as approved by the Board.
2. OBJECTIVE OF THE CODE
2.1. The Code aims to ensure confidentiality of Unpublished Price Sensitive Information (UPSI) and
prevent misuse of such information. The Code encourages timely reporting and adequate disclosure of
price sensitive information by the Promoter(s), Director(s), Key Managerial Personnel, certain
specified employees and other Connected Person. Further, the Code also endeavors to put in place an
adequate and effective system of internal controls to ensure compliance with the requirements given in
SEBI (Prohibition of Insider Trading) Regulations 2015 to prevent insider trading.
3. CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UPSI
3.1. To ensure fair disclosure of events and occurrences that could impact price discovery for securities
issued by PLL in the market, the Promoter(s), Director(s), Key Managerial Personnel and certain
specified employees of PLL shall abide by the principles stated in the “Code of practices and
procedure for fair disclosure of unpublished price sensitive information” provided at Appendix - I.
4. POLICY FOR DETERMINATION OF LEGITIMATE PURPOSES
4.1. To maintain confidentiality of UPSI shared by Insiders in the ordinary course of business, a policy for
determination of “legitimate purposes” for sharing such UPSI with outsiders is provided at Appendix -
II.